PAS 1550:2017 (PAS) and the Implementation Guide

Background

The PAS 1550:2017 is a voluntary code of practice developed with industry by the Environmental Justice Foundation (EJF), The Pew Charitable Trusts, Oceana and the World Wide Fund for Nature (WWF). It provides recommendations for exercising due diligence to assess and minimise the risk of illegally caught seafood in the supply chain, and ensure robust traceability of seafood products and decent working conditions in the seafood industry. It includes guidance on information that can be requested by processors, importers and buyers as part of their due diligence process and risk assessments.

The PAS was developed to help industry assess and mitigate the risks posed by illegal, unreported, unregulated (IUU) fishing in their supply chains. This was with particular reference to the requirements of the EU IUU Regulation (No. 1005/2007) and the need to undertake due diligence to determine if seafood has been legally caught, transported, processed and sold. In this respect, it builds on the BRC Advisory Note for the UK supply chain on how to avoid Illegal, Unreported and Unregulated (IUU) fishery products (published in February 2015). Reflecting the growing concerns of industry regarding human rights issues in seafood supply chains, the code of practice also includes recommendations designed to help industry assess whether or not imports were produced with decent working standards, with reference to the requirements of the International Labor Organisation’s Work in Fishing Convention (ILO C.188).

To ensure it is readily available to anyone in the global seafood industry, EJF, Pew and WWF have made the Code of Practice freely available for download through the Fish Forward 2 Project, which is co-funded by the European Union. Its content does not necessarily reflect the views of the EU.

You can get your copy for free here or by directly mailing one of the contact persons below for your personal PDF copy.

Implementation Guide

The PAS 1550:2017 was published under license from the British Standards Institution (BSI) in July 2017. Following feedback from existing users of the PAS, EJF, Pew and WWF have worked with the input from the Seafood Ethics Action (SEA) Alliance of the UK Seafish Authority since 2019 to develop the PAS 1550:2017 Implementation Guide, which aims to support seafood buyers and their supply chain actors to exercise due diligence and assess risks within their own operations and supply chains, thereby enabling them to avoid purchasing, processing or transporting illegally caught seafood. 

The Implementation Guide splits recommendations into three categories to help users from different starting points adopt recommendations and, eventually, go beyond them: .

  • Base practice is intended for small seafood buyers such as hotels and restaurants who are starting their seafood buying journey.
  • Implementation of PAS/PAS compliant is intended for larger seafood wholesalers, processors and others who already meet the base practice level.
  • Aspirational practice is intended for established seafood processors, wholesalers, retailers and multinational hotel groups that have had several years working in this space.

The Guide also features:

  1. The mapping of PAS recommendations against other standards such as the Global Dialogue on Seafood Traceability (GDST) Standard 1.0, Responsible Fishing Vessel Standard (RFVS) Version 2.0, the Global Seafood Assurances (GSA) Seafood Processing Standard (SPS) 5.0, and the Spanish Association for Standardization and Certification (AENOR) Responsible Tuna Fishing (APR) Standard to indicate where a company or PAS user may already be fulfilling recommendations through implementation of one of these standards or vice versa.
  2. A Risk Assessment Checklist which serves as a template for questions seafood buyers can adapt and distribute within their supply chains to inform their risk assessments.
  3. Flow Diagrams as a tool to inform risk assessments that were created using PAS 1550 recommendations organised by main topics. A legend is located at the top of each flow diagram to indicate what is considered a requirement or a risk assessment consideration, where there is alignment with data gathered in the Global Dialogue on Seafood Traceability (GDST) Standard 1.0, and what different colours of arrows leading from one question to another indicate.
  4. The Shared Resources is a list of various external resources on the topics of IUU fishing, traceability, risk assessment tools and standards, and human rights in seafood supply chains.

The Implementation Guide is available for free download here as a pdf and here as an editable excel spreadsheet. You can also obtain copies by directly mailing one of the contact persons below for your personal copy. The Flow Diagrams are included in a separate document and you can download the printable A4 version here and digital long version here.

These documents have been made available through the Fish Forward 2 Project, which is co-funded by the European Union. Their contents do not necessarily reflect the views of the EU.

Risk Assessments using the Implementation Guide

The purpose of a risk assessment is to gather sufficient information to detect or determine the level of risk, potential exposure to or evidence of illegality occurring in the supply chain. The information provided in the form of a checklist should guide the due diligence process beginning with catching, procuring and processing seafood. 

Generally, a risk assessment will not provide definitive evidence of illegality, but rather inform the need for subjective decisions based on the experience and perception of the seafood processor or buyer and products in question. Where a lack of information, irregularities with regulations or internal policies are identified via the risk assessment process, supply chain actors are able to obtain more information for better decision-making according to the level of risk they are exposed to or should wish to assume. In the event that evidence of illegality is found during this process, supply chain actors should not procure the seafood in question. 

The findings of risk assessments also help inform the levels of risks and point to measures organisations can adopt to mitigate those identified risks. The three main stages to implement risk management are captured in the figure below.

Figure 1. Stages of risk management. Source: Adapted from BSI 2017

The guidance provided in the Risk Assessment Checklist is not an exhaustive list, nor is it descriptive of a full risk assessment process. Rather, it attempts to reflect the overall recommendations of the PAS 1550:2017. The Implementation Guide should be used to help interpret the information collected through the Checklist’s questions.

Translations

Work is underway to translate the PAS and the Implementation Guidance into German and Spanish, and links will be provided here upon completion. 

Contact details

Hayley Swanlund (WWF-UK), hswanlund@wwf.org.uk 

Kristine Beran (Pew), kberan@pewtrusts.org 

Max Schmid (EJF), max.schmid@ejfoundation.org